2025 (5) TMI 333

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..... directed against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (hereinafter referred to as 'the CIT(A)') dated 16.10.2023, for assessment year 2011-12. 2. Ms. Sonia, appearing on behalf of the assessee submits that the assessee had filed an application for admission of additional ground of appeal raising a legal ground challenging validity of t .....

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..... s. 147/148 of the Act may please be quashed." The additional ground raised by the assessee is purely legal in nature and goes to the root of validity of reopening of assessment. Hence, additional ground raised by the assessee is admitted for adjudication. 4. A query was made to the ld. DR regarding the comments of AO on the additional ground raised by the assessee. The ld. DR informed that commu .....

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..... unsigned, it is invalid, and hence, the proceedings arising from the said notice are vitiated. No material has been placed on record by the Department to controvert the submissions of ld. Counsel for the assessee with regard to notice u/s. 148 of the Act being unsigned. In light of the fact that the notice issued u/s. 148 of the Act is unsigned, the same is held to be invalid. Once bedrock for in .....

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